Living Our Values:

McKinsey Code of
Professional Conduct

Our values define who we are as a firm and who Finally, we have this, our Code of Professional
we aspire to be. Conduct, which defines a set of expectations for the
behavior of all firm members. The Code of Professional
They provide the guiding principles that shape our
Conduct does not replace our policies. Rather, it
actions and are essential to fulfilling our two-part
serves as a guide to help colleagues understand the
mission to: help our clients make distinctive, lasting
core elements of our policies and how those policies
and substantial improvements in their performance
are anchored in our values.
and to build a great firm that attracts, develops,
excites and retains exceptional people. The Code of Professional Conduct highlights our
personal responsibility for professional conduct.
We expect all colleagues to live our values every day.
We expect all colleagues to comply with this Code of
And when faced with a difficult situation we expect
Professional Conduct and we expect others working
everyone to challenge themselves, and to consult with
on our behalf, such as contractors, advisors and other
colleagues, to determine what course of action would
suppliers, to act in a manner that is consistent with
be most consistent with our values.
our Code.
While our values guide our behavior and help us to
make the right choices, we also have firm policies.
These policies establish our obligations as members of
the firm and define the rules of conduct in a range of
very specific, often complex, situations. They apply to
all firm members globally, and we expect all colleagues
to comply fully with these policies. We hold ourselves
to the highest standards of integrity and behavior,
and consequently, our policies often go well beyond
what is required by law. Failure to comply with our
policies may result in disciplinary action including
termination of employment.

McKinsey & Company Code of Professional Conduct 1

Our code of professional conduct
Our Code of Professional Conduct serves as a guide
to our values and policies in action and outlines the
expectations we have for all firm members in the
areas of:
1. Serving our clients with the highest
professional standards
2. Creating a working environment that
inspires and motivates our people
3. Fulfilling our responsibility to society
4. Managing risk to the firm
5. Seeking advice and raising concerns

The McKinsey Code of Professional Conduct

is supported by the full set of firm policies.

McKinsey & Company Code of Professional Conduct 2

1. Serving our clients with the
highest professional standards
We are privileged to have the trust of the clients that
we serve, and we earn that trust by always acting
with the highest integrity; by providing objective and
independent advice; by putting our clients’ interests
ahead of our own; and by protecting our clients’
confidential and sensitive information. We expect all
colleagues to act at all times in ways that justify and
reinforce the trust in which we are held.
Client impact
As a firm, we set a high aspiration for the positive
impact we have through our client service. We will only
undertake work where we can be confident that the
objectives of the work are to bring material, positive
and lasting impact; that the impact of our work has the
potential to far exceed our professional fees; that we
will not be pressured to compromise our values; and
that we will be keeping faith with our commitment to
do work that attracts, develops, excites and retains
exceptional people. We are committed to delivering
impact to the best of our abilities to all our clients and
we hold our leaders accountable for that impact. We
expect our leaders to oversee our work, ensure that
the conditions for impact are in place, and to bring
our best capabilities to every situation. All colleagues
have the obligation to speak up if they feel that our
ability to deliver on these aspirations for impact
is compromised.
Client confidential information
In the course of our work we are entrusted with client
and third-party confidential information and we take
exceptional care with the information that has been
entrusted to us. Client confidential information is all
non-public information (written or oral), including
business plans and trade secrets, client names, the
nature of our client services, our recommendations
or advice, client data, and information we purchase at
our clients’ expense. We only share client confidential
information with colleagues who have a legitimate
need to know, or those we know are authorized to
access the information. In their use of social media,
we expect colleagues to safeguard client confidential
information, including anything that could reveal a
client’s identity or our presence there. Colleagues are
also expected to ensure that our clients’ data and the
firm’s data environment is protected from
unauthorized external access by adhering to the
cyber security standards as described in the firm’s
cyber policies.
McKinsey & Company Code of Professional Conduct
Professional independence
We must avoid engaging in outside activities that
could interfere with our responsibilities to our clients
and the firm. It is incumbent on each of us to ensure
that there is never any confusion about whether we
are acting in our capacity as a member of the firm,
or in some other role. Therefore, firm members are
restricted from undertaking employed work outside
the firm, and may not operate or actively manage a
business, run for political office, or accept an official
role in a political campaign. In addition, firm members
are restricted from sitting on the board of directors of
any for-profit company, whether privately held, publicly
listed, or state owned, and must gain clearance prior to
accepting membership on non-profit Boards to ensure
no conflicts exist with our clients. Interim roles in client
organizations are permitted only under a very limited
set of circumstances and only when cleared
by the firm’s Client Service Risk Committee. All firm
members are required to disclose any potential
conflicts of interest, whether real or perceived, and
to consult with relevant firm leaders and governance
bodies on how best to handle the situation.
Misuse of client information
To ensure that there is no risk of insider trading,
firm members and members of their households are
prohibited from purchasing or selling publicly traded
securities (including securities issued by state, local,
or municipal government entities in the US) of any firm
client and are required to pre-clear purchases and
sales of any publicly-traded securities. In addition, firm
members are prohibited from holding an investment
in a non-public company that they serve or making an
investment that creates a conflict of interest for the
firm or themselves. Firm members are also prohibited
from using client confidential information for any
reason other than the service of that client. Such
information cannot be used for personal or political
ends, or in service of a different client.
Client resources and assets
We expect colleagues to treat client assets, including
facilities and equipment, with respect, and to spend
only what is necessary to perform our work to the
highest standard.
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2. Creating a working environment
that inspires and motivates our people
We attract, develop, and seek to excite and retain,
truly exceptional people. We do this through the
opportunities for impact, growth, and development we
provide; by providing a work environment in which our
people feel respected, and can thrive, grow, and be
their best; and by maintaining a caring meritocracy.
Inclusion, diversity and a safe and respectful
work environment
We value an inclusive culture and celebrate diversity
of all types. Diversity in our teams improves the
creativity of our thinking, the quality of our work,
and the development experience for our people.
We expect every colleague to hold themselves
and each other accountable to ensure a working
environment that celebrates the benefits of diversity
and one in which everyone is treated with respect
and dignity, feels welcomed and safe, and can grow,
develop, and perform their best work. We do not
tolerate discrimination, harassment, or bullying in
any form. Our expectations of behavior extend to all
interactions within and beyond the office environment
including team, practice, and office events, and via
electronic communications.
McKinsey & Company Code of Professional Conduct
Our meritocracy
We require all colleagues to uphold both the reality
and the perception of our meritocracy and to do so in
a caring way, with respect, dignity, and empathy. Our
individual evaluation processes – which are critical to
our meritocracy – are holistic and confidential, and all
colleagues are expected to contribute to these with
candor. Attempts to subvert our evaluation processes
runs counter to our values. Any hiring, including for
temporary positions or for the provision of external
services, must comply with firm processes and be
based solely on merit. Favoritism, or the perception
of favoritism, represents a risk to our meritocracy and
as such, we prohibit personal romantic, physical, or
familial relationships between firm members who are
in any kind of supervisory relationship or are actively
working together. We likewise prohibit the hiring of
children of firm Partners. Colleagues are expected to
declare where they have a personal relationship that
may interfere with our meritocracy or create any other
conflict of interest.
Our colleagues’ personal information
We handle our colleagues’ personal data fairly and with
respect and will only collect personal data for specific,
explicit, and legitimate purposes, and limit the data
collected to only what is necessary for the purpose
for which it was collected.
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3. Fulfilling our responsibility to society
As a firm, we are committed to positive social impact.
We help address societal challenges in the way we
conduct ourselves in the course of our business;
through our engagement in our communities; and in
the investments we make to support significant and
lasting impact on pressing social issues.
Societal impact of our activities
In the course of client service, colleagues are expected
to think broadly about the impact of our work on our
clients’ multiple stakeholders, to help our clients to
be mindful of their social impact, to actively debate
the impact of our recommendations on shareholder,
customer, and societal interests, and to always act
in a manner that is consistent with relevant laws and
regulations. We encourage colleagues who wish
to give back to their communities – for example, by
participating in volunteering, non-profit board service,
and charitable giving. Firm members are, however, not
permitted to run for political office or accept an official
role in a political campaign.
Human rights
We are committed to human rights and comply with
all human rights laws. Our commitment to human
rights informs whom we serve and on what topics, and
we will not do work that supports or enables human
rights violations. We do not tolerate physical violence,
threats, bullying, or verbal abuse of any kind in the
workplace, whether in our own or our clients’ locations.
We require suppliers to comply with McKinsey’s
Supplier Code of Conduct which prohibits all forms
of forced labor, child labor and human trafficking,
and requires compliance with all laws regarding
discrimination, harassment and retaliation.
McKinsey & Company Code of Professional Conduct
Environment
McKinsey is committed to minimizing the impact
our firm has on the environment and we seek to
continually strengthen our environmental policies
and practices. We are making efforts to manage, and
reduce, our global greenhouse-gas emissions and
our waste footprint. We expect colleagues to take into
consideration the environmental impact when making
choices about how they work. This includes reducing
emissions from travel, where possible, minimizing
waste, and increasing recycling at McKinsey
locations and client sites.
Competition and trade
We are committed to promoting free, fair and
competitive markets, and compete on the quality and
impact of our work. We abide by international trade
regulations that prohibit or restrict trade with certain
countries, organizations, or individuals. Further,
all colleagues must comply with all relevant laws,
regulations, and internal policies relating to anti-trust,
fair competition, anti-money laundering, funding
terrorist organizations, and trade controls.
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4. Managing risk to the firm
We have the trust not only of the clients that we serve,
but also of the communities in which we operate and
of the talented people who join our firm. That trust,
and our reputation for integrity and independence, is
precious – our ability to have impact for our clients,
provide opportunities for our people, and contribute to
the economies and societies in which we live and work,
depends on it. All colleagues therefore, are expected
to act at all times to proactively manage risks to the
firm and to build and protect the firm’s reputation.
Corruption, bribery, gifts, and entertainment
We will not participate in any form of corruption and we
have an obligation to inform our clients if we encounter
actual or perceived corruption in their organizations.
Firm members, and anyone acting on our behalf, must
not offer gifts or favors to gain any form of advantage
for ourselves, our colleagues, or any third party. Nor
can we accept gifts that are intended to influence us,
and we do not give preferential treatment in our merit-
based hiring processes. We must avoid both the reality
and the perception of improper influence and should
therefore also avoid entertainment which could be
perceived as inappropriate or excessive.
Higher risk client service situations
The firm has identified a number of client service
situations that require colleagues to follow specific
additional requirements to manage risks to clients,
our firm, and our people. These include analytics,
M&A, Public, Social or State-linked Sectors,
Pharmaceutical and Medical Product Compliance,
Purchaser-Supplier engagements, restructuring
and bankruptcy, compensation, software application
delivery and support, work requiring interaction with
regulators, and work conducted in partnership with
third parties. Approval from the Client Service Risk
Committee (CSRC) is required before committing
to work in these areas, and colleagues undertaking
this work are required to be familiar with the specific
policies covering these areas, to undertake all required
training, and to comply with requirements to engage
appropriate experienced practitioners to oversee
the work.
Social media and the press
All colleagues are expected to present themselves
professionally on social media. Even in the use of
private social media accounts, we expect colleagues
to be mindful of the perceptions that can be created.
McKinsey & Company Code of Professional Conduct
Regardless of whether a colleague is speaking for
the firm, or simply using social media for personal
use, we expect colleagues to maintain both client
and firm confidentiality, and to protect the firm’s
reputation. Colleagues must not present their personal
political views in ways that could compromise the
firm’s reputation for political neutrality. All external
publication and communication with the press requires
approval by firm External Communications and
colleagues are required to complete media training
prior to any interview with journalists or bloggers.
Data security and protection
All colleagues are required to protect the firm’s data
and its data environment from unauthorized access. All
digital deployments by the firm including applications,
platforms, technology and third-party products,
must conform to approved standards to ensure that
confidential information is protected by strong security
controls. Any exceptions must be approved by the
Cyber Risk team and colleagues who are uncertain
about the security of a system or technology should
e-mail for help.
McKinsey resources and assets
We expect colleagues to be thoughtful in how they
use firm resources and protect the firm’s information
and assets. McKinsey assets, including proprietary
information, software, frameworks, tools and
methodologies, must be used only in accordance
with firm policies and for firm-related activities.
Colleagues may not use McKinsey resources such
as e-mail distribution lists for political purposes, for
soliciting investments, or for other personal interests.
We expect all colleagues to be fiscal stewards of the
firm, to fully and consistently comply with our expense
policies, and to reflect on how their use of resources
would be perceived externally and by their colleagues.
Accurate records
We maintain accurate records for the appropriate
length of time to enable us to comply with all relevant
laws and regulations. It is explicitly against our policy
to maintain firm or client records outside of the firm’s
systems, or to destroy, falsify or alter records that are
required to be maintained (for example, in the context
of an investigation). Colleagues are expected to file
any required firm records, such as expense reports
and timesheets, accurately and in a timely way.
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Working with third parties
We partner with other firms and engage individuals,
including Senior Advisors, from outside the firm
to bring the best to our clients and the firm. These
relationships are increasingly important enablers of our
impact and innovation. At the same time, working with
other organizations and individuals raises potential
financial, legal and reputational risks. These situations
therefore require additional syndication and expert
advice. All colleagues are required to ensure that
any third-party partnering with the firm or delivering
services to the firm is appropriately vetted, and to
comply with our consulting intermediaries, external
workers and partnering policies.

McKinsey & Company Code of Professional Conduct 7

5. Seeking advice and raising concerns

Not every situation can be neatly captured in a policy Hotlines

or code of conduct, and colleagues should always
seek advice when faced with a difficult situation,
or whenever they are unsure of the correct course
of action.
If a colleague observes something they believe may
be inconsistent with our values, our policies, or this
Code, could put the firm or an individual colleague at
risk, or may be against the law, they have an obligation
to speak up.
Colleagues in any kind of supervisory position,
for example Partners or Managers, have an
additional obligation to report anything that could
be a violation of our Ensuring an Environment Free
from Harassment or Discrimination Policy.
The firm does not tolerate retaliation against a
colleague who in good faith raises a concern about
any aspect of professional conduct, or who fulfills their
obligation to participate honestly in a firm or external
investigation. Retaliation in any form is a violation
of policy and may result in disciplinary action,
including termination of employment.
The following resources are available to all colleagues
to seek advice, ask a question or raise a concern.
We recognize there are times where colleagues may
feel the need for an opportunity to raise a concern or
ask a question without coming forward directly to a
colleague. For those instances, we have established
hotlines, as an alternative vehicle for colleagues to use.
You may ask a question or raise a concern through an
internal link, which is hosted by an external service
provider to keep the information confidential, to the
extent permitted by law.
Ombuds
The firm Ombuds are available to all firm members
to provide informal, confidential advice and support.
As an informal resource, our Ombuds will not direct
you on what to do, act on anything you discuss, or
(except if they determine there is imminent risk of
serious harm) escalate your situation to others inside
or outside the firm. Our Ombuds will offer assistance
to help colleagues make a decision on how and where
to formally report the concern. If you are aware of a
potential breach of our values, professional standards,
policies, or the law, please raise it through one of the
methods listed above so the firm can review it and take
appropriate action.

Advice from a colleague

Our aspiration is that colleagues feel comfortable
seeking advice or raising concerns directly with a firm
colleague. Examples of colleagues who may be able
to help address your concern include:
— The ED or other leader of your client service team
— Your DGL, Office Managing Partner, cell leader,
supervisor, or department manager
— Your Regional People Leader, PD or HR
— The firm’s Chief Risk Officer, Chief People Officer,
General Counsel or leader of Personnel Risk
— Any member of the firm Legal department
— For concerns related specifically to the behavior
of a Partner or Senior Partner:
Chair of the Professional Standards Committee,
Leader of Personnel Risk, or Chief People Officer
— For concerns related to client service:
Any member of the Client Service Risk Committee
(CSRC) or our Director of Risk

McKinsey & Company Code of Professional Conduct 8

Conclusion

Our Code of Professional Conduct highlights that This Code of Professional Conduct is intended to be
each of us has an obligation to maintain the highest a living document. The Risk, Audit and Governance
professional standards in our client service; create Committee of the Shareholders Council is responsible
an environment in which our people are respected, for periodically refining and updating the content of
inspired and motivated; consider the wider this Code.
implications of our actions on society; and uphold
To provide input or suggestions to improve this Code of
the firm’s reputation.
Professional Conduct please see the firm’s intranet.
We are each responsible for applying the standards
outlined in this code, and of taking the responsibility
to speak up and voice any questions or concerns
related to possible violations of this code, of our
values, our policies, or the law.
Following this code will allow us to truly live up to
our values, fulfill our dual client service and people
mission, and continue to earn the trust of the clients
we serve and the communities in which we live and
work. Our collective aspirations for positive impact
in the world depend on that trust and therefore on
us living by the behaviors highlighted in this Code
of Professional Conduct.

Adopted: May 11, 2019

Updated: November 2020

McKinsey & Company Code of Professional Conduct 9